In Republic v. Hong,⁠1 it was held in essence that an applicant for naturalization must show full and complete compliance with the requirements of the naturalization law; otherwise, his petition for naturalization will be denied. This ponente has likewise held that “[t]he courts must always be mindful that naturalization proceedings are imbued with the highest public interest. Naturalization laws should be rigidly enforced and strictly construed in favor of the government and against the applicant. The burden of proof rests upon the applicant to show full and complete compliance with the requirements of law.”⁠2

Section 2 of the Revised Naturalization Law or CA 473 requires, among others, that an applicant for naturalization must be of good moral character and must have some known lucrative trade, profession, or lawful occupation. In regard to the requirement that the applicant must have a known lucrative trade, this ponente declared:

Based on jurisprudence, the qualification of “some known lucrative trade, profession, or lawful occupation” means “not only that the person having the employment gets enough for his ordinary necessities in life. It must be shown that the employment gives one an income such that there is an appreciable margin of his income over his expenses as to be able to provide for an adequate support in the event of unemployment, sickness, or disability to work and thus avoid one’s becoming the object of charity or a public charge.” His income should permit “him and the members of his family to live with reasonable comfort, in accordance with the prevailing standard of living, and consistently with the demands of human dignity, at this stage of our civilization.”

Moreover, it has been held that in determining the existence of a lucrative income, the courts should consider only the applicant’s income; his or her spouse’s income should not be included in the assessment. The spouse’s additional income is immaterial “for under the law the petitioner should be the one to possess ‘some known lucrative trade, profession or lawful occupation’ to qualify him to become a Filipino citizen.” Lastly, the Court has consistently held that the applicant’s qualifications must be determined as of the time of the filing of his petition.⁠3 (Emphasis supplied)